CFA三级第一册课后 2020 Level III - SchweserNotes Book 1.pdf

An adequate compliance system must meet industry standards, regulatory requirements, and the requirements of the Code and Standards. Members with supervisory responsibilities have an obligation to bring an inadequate compliance system to the attention of firm’s management and recommend corrective action. A member or candidate faced with no compliance procedures or with procedures he believes are inadequate must decline supervisory responsibility in writing until adequate procedures are adopted by the firm. Recommendations for members A member should recommend that his employer adopt a code of ethics. Members should encourage employers to provide their codes of ethics to clients. Once the compliance program is instituted, the supervisor should: Distribute it to the proper personnel. Update it as needed. Continually educate staff regarding procedures. Issue reminders as necessary. Require professional conduct evaluations. Review employee actions to monitor compliance and identify violations. Respond promptly to violations, investigate thoroughly, increase supervision while investigating the suspected employee, and consider changes to prevent future violations. Recommendations for firms Do not confuse the code with compliance. The code is general principles in plain language. Compliance is detailed procedures to meet the code. Compliance procedures should: Be clearly written. Be easy to understand. Designate a compliance officer with authority clearly defined. Have a system of checks and balances. Establish a hierarchy of supervisors. Outline the scope of procedures. Outline what conduct is permitted. Contain procedures for reporting violations and sanctions. The supervisor must then: Disseminate the compliance program to appropriate personnel and periodically update the program. Continually educat